CAEN Rev. 3 for SRLs in 2026: 25 September deadline, free ONRC update and what you risk

Tavoris’s blog covers choosing CAEN codes at incorporation, the ONRC dossier, post-incorporation amendments (office, director, capital), and online filing. CAEN Rev. 3 is mentioned only briefly in the amendments guide, but searches for “CAEN Rev 3 25 September 2026 deadline”, “free CAEN update ONRC”, “Rev 2 to Rev 3”, “Annex 2a activity object”, and “what if I don’t update CAEN” surged in August 2026 — with 25 days left until the legal deadline.

Five dominant topics: (1) what changed in the nomenclature (NACE Rev. 2.1), (2) the 25 September 2026 deadline in Government Decision 284/2025, (3) who must file and who is already on Rev. 3, (4) the free Annex 2a point 8 procedure versus changing the activity object, (5) what happens after the deadline. Data updated as of 31 August 2026.

CAEN Rev. 3 is the nomenclature in force from 1 January 2025, approved by INS President’s Order 377/2024 (Official Gazette no. 385/25 April 2024). It replaces CAEN Rev. 2 (used since 2008) and aligns Romania with the European NACE Rev. 2.1 classification (Commission Delegated Regulation (EU) 2023/137).

This is not a re-incorporation: the tax ID (CUI) and trade-register number stay the same. You update the registered activity object so the certificate states the Rev. 3 version. Even if the numeric code is unchanged, companies formed before 2025 still need the version update.

Three practical change types: (a) merger — several Rev. 2 classes become one Rev. 3 class; (b) split — one old class becomes several new classes, and you pick the one that matches real activity; (c) new name/grouping with the same number. A frequent example: Rev. 2 class 4939 (other passenger land transport) was split; alternative transport / ridesharing typically maps to Rev. 3 class 4933. Use the official INS correspondence table (insse.ro, CAEN section), not an unofficial converter.

Government Decision 284/2025 (Official Gazette no. 257 of 25 March 2025) set an 18-month implementation period from publication. The deadline is 25 September 2026. Until then, public bodies accept both Rev. 2 and Rev. 3; afterwards, only Rev. 3 remains valid.

As of 31 August 2026, 25 calendar days remain. ONRC has not published a general deadline extension in August 2026: treat the date as firm. Filing volume rises in September — last-day submissions risk counter queues and myportal.onrc.ro validation delays.

There is no express contravention fine solely for “late CAEN Rev. 3”. The risk is operational: after the deadline, other ONRC mentions, permits, and tax filings refer to the new nomenclature. Details in the consequences section.

The duty covers entities registered with ONRC before 1 January 2025 that still have a Rev. 2 activity object: SRLs, SAs and other companies, plus PFA, II and IF. Market estimates based on end-2024 ONRC data are on the order of 1.7 million entities (legal persons and PFAs combined).

Exempt: SRLs (and other forms) incorporated from 1 January 2025 — including dossiers prepared in Tavoris in 2025–2026 — already received Rev. 3 codes. You do not file Annex 2a only for recoding. If your certificate already states CAEN Rev. 3, check the extract once and stop.

PFA: maximum 5 activity classes (GEO 44/2008). II: maximum 10 classes. If the Rev. 3 mapping produces more classes than the cap, you must choose and, where needed, drop some activities. An SRL does not have the same numeric cap as a PFA, but the list should still match real activity — see our guide on choosing CAEN at incorporation.

A simple update (Rev. 2 → Rev. 3 recoding only, without adding or removing activities versus the existing object) is filed with the Trade Register application — Annex 2a for SRLs. In section V (object of the application), tick point 8: “update of the activity object according to CAEN Rev. 3”. You do not need new articles of association, a GMS resolution, or a sole-associate decision if you are not changing the content of the object.

Documents: the application; an original power of attorney only if someone other than the legal representative files. Channels: myportal.onrc.ro (qualified electronic signature), counter, or post/courier. Cost: RON 0 register fee for simple recoding. ONRC issues an updated registration certificate free of charge. The CUI does not change.

If you add or drop activities, change the principal CAEN, or combine recoding with office, director, or capital changes: it is no longer “point 8 only”. You also complete the mentions at point 4, attach a GMS resolution / sole-associate decision, updated articles (Rev. 3 codes), and pay standard fees (including Official Gazette Part IV publication where required). The ONRC amendments guide covers those mixed filings — do not confuse them with the free recoding.

As of 31 August 2026, ONRC has not published a catalogue of fines specific to missing the CAEN Rev. 3 update. The real consequence: after the deadline, the operational nomenclature is Rev. 3 only. The next mention (office, associates, director, capital, dissolution) may be conditioned on recoding — a filing “for something else” starts with CAEN.

ANAF and other authorities (operating permits, regulatory approvals) will report activity against Rev. 3. A mismatch between an old Rev. 2 certificate and new forms can block returns, public contracts, or permit renewals. For PFAs on income norms, the nomenclature was realigned by Order 1.960/2025 — SRLs do not use income norms, but the same principle applies: the tax vector does not change automatically through recoding; Form 700 matters only if real activity or the regime (micro, VAT) changes.

Do not delay because “there is no fine”. The cost is time: an urgent October 2026 mention (director or office change) will not go through until you are on Rev. 3.

Complete these steps before 25 September 2026:

Tavoris prepares the SRL incorporation dossier. Codes in the app follow the Rev. 3 nomenclature used at generation — a new 2026 SRL already comes out on Rev. 3, without an Annex 2a recoding filing.

Tavoris does not file CAEN Rev. 3 updates for existing companies, does not complete Annex 2a mention forms, and does not submit the application to ONRC. Recoding an SRL formed before 2025 remains yours (or your proxy’s), on myportal.onrc.ro or at the counter.

Informational guide as of 31 August 2026. INS Order 377/2024, GD 284/2025, MJ Order 2938/C/2024, ONRC procedures, and the correspondence table may change. Verify onrc.ro and insse.ro. Not legal or tax advice.